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Last week, the nine Northeast and Mid-Atlantic states that participate in the Regional Greenhouse Gas Initiative (RGGI) submitted their comments about the Clean Power Plan (CPP)—the EPA’s flexible, state-based program to cut greenhouse gas pollution from existing power plants by 30 percent by 2030. Based on their considerable experience cutting carbon pollution, it’s no surprise the RGGI states expressed strong support for the CPP and urged the EPA to go much further in its final plan, with far more ambitious pollution cuts. Such cuts are not only do-able, they told the EPA, based on their own experiences, everyone will benefit.

These states—Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island and Vermont—are, along with California, the most experienced in the nation at cutting carbon pollution, with power-plant greenhouse gas levels down in the Northeast/Mid-Atlantic region by almost 40 percent since 2005. The RGGI experience has taught these states that cutting carbon, especially through a market-based regional program, brings with it tons of additional advantages—job creation, lower energy bills, significantly improved public health. Cutting carbon isn’t just our moral responsibility, they told the EPA. It’s an economic opportunity we can all embrace as we work to finally stabilize our climate.

An aside here: It’s worth contrasting the RGGI states’ comments and actions with those of a group of a dozen heavily-polluting states that have little experience cutting carbon from power plants but are nevertheless suing the EPA over the CPP. These states claim the EPA’s plan is illegal and will have “devastating effects” on jobs and their state economies. The RGGI states, instead, remind both the EPA and the rest of us that in the real world carbon cuts not only work to everyone’s advantage, but can be achieved far more quickly than the current plan requires. A faster pace of emissions reductions can “be realized cost effectively,” the nine states wrote, “while creating jobs, maintaining reliability, and producing economic benefits.” In other words, bigger cuts will also create more jobs, save electric customers billions more on their energy bills, and keep our electric grid strong.

But back to the mid-2000s. The governors created a market in which power-plant-pollution permits are auctioned off quarterly and states invest the resulting revenue in energy efficiency upgrades and clean, renewable energy, among other carbon-cutting strategies.

Since the first auction took place in early 2009, the region has experienced the following impressive co-benefits:

RGGI demonstrates not only that cutting carbon pollution works, but that what the EPA calls “regional compliance strategies” work and work cost-effectively. “Importantly,” the RGGI states wrote last week, “a mass-based program like RGGI”—that is, one that consists of a state or regional cap on carbon that declines over time—“avoids many of the complications of a rate-based approach,”—an approach that says how much pollution per megawatt hour power plants can produce—“…while also simplifying compliance and enforceability.” (Last week, the EPA released additional guidance that will provide states with greater clarity on how to convert their rate targets to mass targets. That should help facilitate discussions both within and among states about how to pursue regional compliance strategies. )

Regional approaches, of course, can take many forms. They can include everything from new states joining RGGI outright, to merely adopting a state cap and entering into agreements with the RGGI states to “honor each other’s currency,” something that will allow the trading of carbon credits within the same market.

In RGGI’s case, each state devises its own approach to cutting carbon, but the scale of the regional endeavor helps drive efficiencies that individual states can’t realize on their own. RGGI “provides an off-the-shelf model that is well-aligned with the goals and structure of the CPP,” the RGGI states wrote in their comments. “In order to ensure that other states can take advantage of the opportunity provided by the RGGI model, the EPA should provide strong support for states that implement RGGI-like programs or become participants in RGGI, an outcome that would be welcomed by the RGGI states.”

While regional approaches present efficiencies that individual state programs do not, both offer many opportunities to make significant emissions cuts.

The RGGI states, in particular, have found that renewable energy “can be a cost-effective prong of a wide-ranging emission reduction strategy,” the states advised the EPA. And, with respect to energy efficiency, they reminded the agency, there’s still boat loads of low-hanging fruit that’s ripe for the picking.

In their more than 30 pages of comments, the RGGI states relied heavily on their real-world experience to advance the case for bigger pollution cuts—cuts that make good use of the country’s energy efficiency and renewable energy resources. Indeed, the RGGI states did just that recently, significantly lowering their pollution cap to improve the program’s effectiveness. The group speaks from experience.

All of it shows that cutting carbon from power plants works to everyone’s benefit—job seekers, families and businesses with energy bills to pay, and everyone who breathes.

In evaluating states’ responses to the CPP, whom should you believe? The nine states with a ton of experience cutting carbon or the dozen that have no experience but nevertheless claim to be experts on the consequences? I’m going with the RGGI states, and the EPA should, too.